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Effective July 17, 2018.

Fuze, Inc., together with its affiliates and subsidiaries, (collectively, “Fuze”) provides enterprise global voice, video, messaging, and collaboration software and applications that our customers use to communicate more effectively and efficiently.

This Guest User Privacy Statement explains how we collect, use, disclose, and otherwise process the personal information of guests invited by our customers to use Fuze products and services, including Voice, Collaboration, Guest, Data, Contact Center, and the Fuze application programming interfaces (collectively, the “Services”). Fuze is the data processor with respect to guest users’ personal information, and the Fuze customer that invited the guest to use the Services is the data controller.

At Fuze, we love our products, so we use them. This means that a Fuze employee may invite you to use the Fuze Services. When this happens, Fuze handles your information as both the “customer” and Fuze under this Guest User Privacy Statement.

Fuze’s processing of guest user personal information in connection with the Services is governed by this Guest User Privacy Statement, our customer agreements, and our Privacy Policy. In the event of any conflict between this Guest User Privacy Statement and a customer agreement, the customer agreement will control to the extent permitted by applicable law. If you are a guest user of the Services and would like to learn about how a particular customer handles your personal information, we encourage you to read the customer’s privacy statement or contact the customer directly.

Information We Collect

Information provided to us by guest users in connection with their use of the Services. This may include personal information that guest users provide when they:

  • Login to the services (such as first and last name, email address, telephone number(s), fax number, employer name, department and job title, device ID, and profile picture);
  • Upload documents, such as presentations, to the Services;
  • Participate in a chat when using the Services;
  • Contact customer support or otherwise correspond with us by phone, email, or other means.

Social media account information. Guest users may link a social media account to the Services. In those circumstances, Fuze may collect the end user’s email address and profile picture associated with the social media account.

Information about guest users’ use of the Services. We collect information about guest users’ use of the Services, including:

  • Call details, such as time placed, caller, number dialed, call recipient, whether any media was played, and whether the call was answered, dropped, or other disposition;
  • Information provided through and use of the messaging platform, voicemail feature, and video conferencing;
  • Location data where the guest user has agreed to share such information with Fuze through a consent mechanism on the guest user’s mobile device;
  • Recordings of calls or video conferences, where such features are activated by our customer;
  • Media generated and shared through Fuze Meetings and Collaboration platforms, where such features are shared by a Fuze customer;
  • Information collected by automated means, such as cookies and web beacons, as described in the Fuze Privacy Policy

Choosing Not To Share Your Personal Information

Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Services, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with the Services and may need to close your account. We will tell you what information you must provide to receive the Services by designating it as required in the Services or through other appropriate means.

How We Use Information

We use the information we collect at the instruction of our customers and in accordance with our customer agreements, to provide the Services and for related internal purposes, including:

  • To enable guest users to access and use the Services;
  • To provide information about the Services, such as important updates or changes to the Services and security alerts;
  • To customize the end user experience, such as personalizing content and features to better match interests and preferences;
  • To improve the Services and develop new products and services;
  • To respond to inquiries, complaints, and requests for customer support.

We may also use personal information as we believe necessary or appropriate to (a) comply with applicable law; (b) enforce the terms and conditions that govern the Services; (c) protect our rights, privacy, safety or property, and/or that of you or others; and (d) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

How We Share Information

We share the information we collect:

  • With the Fuze customer that invited to you to use the Services;
  • With third party service providers that help us manage and improve the Services;
  • With Fuze subsidiaries and corporate affiliates.

We also enable guest users to share information when using the Services, e.g., by sharing presentations or participating in chats to share information with other call participants, including other guests.

We may also share personal information with government, law enforcement officials or private parties as required by law, when we believe such disclosure is necessary or appropriate to (a) comply with applicable law; (b) enforce the terms and conditions that govern the Service; (c) protect our rights, privacy, safety or property, and/or that of you or others; and (d) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

We may sell, transfer or otherwise share some or all of Fuze’s business or assets, including personal information, in connection with a business deal (or potential business deal) such as a merger, consolidation, acquisition, reorganization or sale of assets or in the event of bankruptcy.

Information Security

Fuze uses appropriate, commercially reasonable physical, electronic, and procedural safeguards to protect personal data from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction in accordance with applicable law. We cannot, however, guarantee that any safeguards or security measures will be sufficient to prevent a security problem.

Data Subject Rights

European data protection laws give individuals certain rights regarding their personal information:

  • Access. Provide you with information about the processing of your personal information and give you access to your personal information.
  • Correct. Update or correct inaccuracies in your personal information.
  • Delete. Delete your personal information.
  • Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
  • Restrict. Restrict the processing of your personal information.
  • Object. Object to the reliance on legitimate interests as the basis of the processing of your personal information.

If these European data protection laws apply to you, you can submit these requests to the Fuze customer that invited you to use the Services. This customer is the data controller of your personal information, and is responsible for receiving and responding to your requests to exercise any rights afforded to you under applicable data protection law. Fuze will assist customers in responding to such requests as necessary. If you would like to submit a complaint about the use of your personal information or the response to your requests regarding your personal information, you may contact the Fuze customer as described in the customer’s privacy policy or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.

Cross Border Data Transfer

Fuze may transfer personal information about its guest users outside of the country in which guest users are located, including to the United States. Whenever we transfer your personal information out of the EEA to countries not deemed by the European Commission to provide an adequate level of personal information protection, the transfer will be based on one of the following safeguards recognized by the European Commission as providing adequate protection for personal information, where required by EU data protection legislation:

  • Contracts approved by the European Commission which impose data protection obligations on the parties to the transfer. For further details, see European Commission Model contracts for the transfer of personal information to third countries.
  • For transfers to recipients in the United States, Fuze may, in lieu of using the contracts referenced above, ensure they participate in the EU-US Privacy Shield Framework.

Please contact the Fuze customer that invited you to use the Services if you want further information on the specific mechanism used when transferring your personal information out of the EEA.

Data Retention

Fuze retains personal information for as long as necessary to (a) provide the Services; (b) comply with legal obligations; (c) resolve disputes; and (d) enforce the terms of customer agreements.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Creation of Anonymous Data for Analytics

We may create anonymous data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous data by excluding information that makes the data personally identifiable to you, and use that anonymous data for our lawful business purposes.

Third Party Products and Services

The Services may integrate with or enable access to third party tools. Third party tools registered, installed, or accessed by end users are governed by those third party providers’ privacy notices. Please review those notices carefully, as Fuze does not control and cannot be responsible for these providers’ privacy or information security practices.

Changes to this Guest User Privacy Statement

We reserve the right to modify this Guest User Privacy Statement at any time. We encourage you to periodically review this page for the latest information on our privacy practices. If we make material changes to this Guest User Privacy Statement you will be notified via e-mail (if you have an account where we have your contact information) or another manner through the Services that we believe reasonably likely to reach you (which may include posting a new privacy policy or a specific announcement on our websites).

Any modifications to this Guest User Privacy Statement will be effective upon our posting of the new terms and/or upon implementation of the new changes on the Service (or as otherwise indicated at the time of posting). In all cases, your continued use of the Services after the posting of any modified Guest User Privacy Statement indicates your acceptance of the terms of the modified Guest User Privacy Statement.

Contact Us

If you have any question about this Guest User Privacy Statement, you can contact our privacy team at:

Email:

privacy@fuze.com

Address:

Fuze Privacy

2 Copley Place, FI. 7

Boston, Massachusetts 02116 USA

If you live in the EU, you can contact our Data Protection Officer at:

Email:

dpo@fuze.com

Address:

Fuze DPO c/o Yung Shin Van Der Sype, time.lex,

Joseph Stevensstraat 7 rue Joseph Stevens,

1000 Brussels, Belgium

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